Financial hardship policy

Policy statement

We understand customers experiencing financial hardship may find it difficult to pay their account. We recognise we have an ongoing social obligation to ensure vulnerable customers are treated with fairness, integrity and compassion. We are committed to working with our customers to find an appropriate payment solution that is effective and sustainable.

Purpose

The purpose of this policy is to outline the minimum standards we apply to customers who do not have the capacity to pay their accounts due to financial hardship. It communicates our position and provides guidance to employees, customers and stakeholders. Our aim is that a customer in genuine financial hardship:

receives the maximum assistance possible once contacting us or having been directly referred to us via financial counsellors

will engage with us allowing early identification

is treated with fairness, integrity and confidentiality

will have a range of flexible payment options tailored to meet their individual needs

is encouraged and receives assistance to proactively manage their accounts

is provided with information and advice on concession eligibility, water efficiency and the relevant support programs available

This policy reinforces our commitment to manage debt effectively in line with our social responsibility.

Whilst the owner is liable for all charges for the property, we will extend the conditions of this policy to all customers as defined in the Water Services Code of Conduct (Customer Service Standards) 2013 with prior consent from the land owner. This includes tenants who are registered to receive water use bills as directed by the owner.

Scope

This Financial Hardship Policy applies to residential customers who are experiencing financial hardship. It is:

applied by staff in Credit Management who are responsible for the recovery of overdue debt

used as a reference by all employees and contractors of the Corporation who interact with customers with outstanding charges, and who suspect or have confirmed, that the customer is experiencing financial hardship

This policy does not apply to non-residential customers or people having payment difficulties who are not in financial hardship1.In recognition that these customers may also need support, our trained staff can offer advice and a range of flexible payment options to assist them.

A “customer” is defined as –
a) an owner of the land in respect of which the water services are
provided; or
b) an occupier of the land in respect of which the water services are
provided

Financial Liability

Under Section 126 of the Water Services Act 2012, the land owner is liable for all charges

ERA

Economic Regulation Authority

FCAWA

Financial Counsellors Association of Western Australia

HUGS

Hardship Utility Grant Scheme

WACOSS

Western Australian Council of Social Service

Financial hardship

A state of more than immediate financial disadvantage that results in a customer whose intention is to pay an outstanding amount, being unable to pay without affecting their ability to meet their or their dependant’s basic living needs

Payment difficulties

A state of immediate financial disadvantage that results in a customer being unable to pay an outstanding amount as required, due to a change in personal circumstances

In 2008 we identified a need for proactively developing and implementing a financial hardship policy as increasing numbers of customers were experiencing payment difficulties. Whilst we were not regulated to do so, we demonstrated our commitment by exceeding regulatory requirements to meet the needs of our customers.

support the ’shared responsibility’ policy model where utilities, the government and community groups all share the responsibility for assisting customers in financial hardship.

Since then, our ongoing engagement and consultation with various social sector agencies (including FCAWA and WACOSS) has improved our awareness of customers’ needs, and our ability in dealing with those in financial hardship. We understand we need to be socially responsible using best practice and we have enhanced our communications and processes to allow better engagement with our customers facing financial difficulty.

This policy complies with the Water Services Code of Conduct (Customer Service Standards) 2013.

The Manager Customer Centre is responsible for the strategic direction, operation and management of our hardship policy and associated programs, including monitoring the effectiveness of the financial hardship policy. All Credit Management employees are responsible for the application of the policy. All frontline customer service employees who assist customers having financial difficulties are required to be aware of this policy and the options available to assist them.

A customer can be identified as being in financial hardship either by self-assessment, an internal assessment process or by an independent financial counsellor or other skilled consumer representative.

The following indicators are considered when determining whether a customer is in financial hardship:

Temporary financial hardship

Customers in temporary financial hardship are those who are experiencing financial difficulties due to a sudden and/or temporary change in circumstances that adversely affect their finances. These customers generally require flexibility and we can assist by offering an extension of time to pay or a payment arrangement. They may also qualify for HUGS. Financial hardship may be caused by, but not limited to sustained incidence of one or more of the factors listed below:

Received a number of bills at the same time.

Incurred an unexpected emergency or one-off expense.

Loss of the customer’s or family member’s primary income.

Spousal separation or divorce.

Physical and/or mental health issues or a chronically ill child.

Loss of a spouse or loved one.

Domestic violence.

Budget management issues associated with a low income.

Becoming financially over-committed.

Long-term financial hardship

Long-term hardship customers are generally those with low or fixed incomes who may require ongoing assistance. They may also qualify for the Water Assist Scheme. Based on the customer’s individual circumstances, we may refer them for qualified advice from a free counselling service in order to assess their eligibility for the scheme.

choose from various alternative payment arrangements in accordance with their circumstances and capacity to pay. The customer’s future water use needs will be taken into account when entering into a payment plan. At this time the customer may also receive water efficiency information that may assist in managing/reducing future water use

payment plans being reviewed each time a new bill is issued

an interest and fee exempt payment arrangement as long as they meet their commitment to it

receive written confirmation of the agreed arrangement on request

renegotiate the amount of their instalment if there is a change in circumstances. Future bills can be incorporated into the customer’s payment plan providing they have the capacity to pay under their agreement. A renegotiation of the new amount will occur to ensure it is suitable to both parties

be referred to a free counselling service to receive independent advice. This will involve financial counsellors and the customer in setting up a suitable payment plan. During this time recovery action will cease pending the establishment of an agreed payment arrangement

be advised of the amount of any historical debt and the basis of that debt

be shielded from legal action, additional recovery costs and restriction of supply as long as they have agreed to an arrangement and are meeting their commitment to it

be advised in writing that recovery action will continue if they fail to meet the agreed payment arrangement schedule and fail to actively work with us to address the situation.

Tenants

Tenants experiencing payment difficulties can contact us directly to discuss your options and situation. We will negotiate a proposed payment plan with you and notify the land owner of the proposed plan on your behalf, as their consent is required for the plan to proceed. We can also provide you with assistance and information on ways to manage future water use bills.

Owners

On request, as a service to land owners, we will issue water use bills to either their nominated real estate agent or tenant. By authorising a tenant to receive water use bills, you also authorise us to discuss matters in relation to the water use bills directly with them. However, this does not affect your liability for the charges. Where the water use bill is sent to anyone other than the land owner and remains unpaid, formal recovery action will commence against the land owner. If you are having payment difficulties or financial hardship please contact us to make a suitable payment plan. If your tenant is registered with us to receive water use bills and contacts us to request a payment plan for water use charges, we will inform you of the proposed plan for your consent.

If you are in financial hardship, we will consider reducing the amount you owe to us. In addition, we will not commence or continue proceedings to recover your debt:

while we are assessing whether or not you are in financial hardship

if you are complying with your payment plan or another payment arrangement you have with us.

If you do not comply with your payment plan or other payment arrangement, we may commence debt recovery proceedings. When collecting your debt, we will comply with Part 2 of the Australian Competition and Consumer Commission and Australian Securities and Investments Commission’s debt collection guidelines for collectors and creditors.

We will not reduce the rate of flow of your supply of drinking water in the following cases:

While we are assessing whether or not you are in financial hardship.

If you are complying with your payment plan or another payment arrangement you have with us.

If you are experiencing payment difficulties or financial hardship.

If you are a tenant in the property.

If you do not pay your bill by the due date, we may fit a device to your meter which reduces the flow of your drinking water. If we restrict the supply of water to you, we will provide a flow sufficient for health and hygiene purposes. We will restore the water supply when either:

Redirection of bills – you can nominate to have the bill redirected at no charge to a third party or an alternative postal address

Payment options – ongoing management of bills through regular deductions is available through Centrepay and direct debit. Other payment methods are available through internet, phone or post. For more information on payment methods please refer to your bill.

Concessions – you may be eligible for a concession if you hold a Pensioner or State Concession card, Commonwealth Seniors Health Card with a WA Seniors Card or a WA Seniors Card. Further information on eligibility criteria can be found on our website.

Financial relief
Hardship Utilities Grant Scheme (HUGS) is a State Government scheme that provides assistance to people who are in financial hardship and unable to pay their utility accounts. For eligibility criteria please contact us.

Water Assist Scheme is designed for customers in financial hardship who require a greater level of assistance. This scheme can help you manage your water accounts Water Assist is a regular and interest free payment arrangement where the Water Corporation will match any payment made by you, dollar for dollar. Based on your individual circumstances you may be eligible and we will work together to assess your eligibility.

Financial counsellors – we will advise you of any financial counselling services or other organisations that may be available to you. Financial counsellors offer free, confidential and independent information to help you take control of your financial situation. Alternatively, the Financial Counsellors’ Association of WA (FCAWA) can refer you to a financial counsellor in your area, or you can call the FWAWA’s helpline:

Fees and charges – residential fees and charges information is readily available on our website www.watercorporation.com.au/my-account/rates-and-charges. Interest charges are raised on all overdue service and water use bills except accounts for registered concession card holders. Customers in financial hardship are not charged interest. We do not charge late payment fees.

We consulted with the Western Australian Council of Social Service (WACOSS) and the Financial Counsellors’ Association of Western Australia (FCAWA) on the content of this hardship policy. A copy of this policy and covering letter was issued to these organisations with an invitation to comment and provide feedback.

We will also undertake the following action to facilitate best practice and continuous improvement:

key cultural and social issues for significant customer groups and communication skills for engaging with customers in financial hardship;

water efficiency information and advice

the Water Assist scheme.

To ensure this process is maintained to the desired standard, staff performance is assessed through monitoring of calls for Call Centre staff and qualitative audits. Credit Management staff who case manage individuals experiencing financial hardship have comprehensive training on a range of social and community issues to improve their understanding of the issues that affect people in financial hardship. In addition we will:

engage with stakeholders in the development and review of training programs

provide training to new staff and schedule refresher courses where appropriate.

The customer’s commitment to us

We will do our best to assist customers experiencing financial hardship. If you are experiencing financial hardship, we would like you to contact us as soon as possible to discuss your situation. We can offer you a payment plan, free of interest, over an extended period of time, if you agree and maintain the arrangement.

We also offer a range of schemes/arrangements such as Water Assist and may suggest HUGS for eligible customers who need additional help.

In return, we ask that the customer:

agree and maintain a suitable payment arrangement

keep us informed of any changes in their circumstances

contact us to request an alternative arrangement if they are having difficulty maintaining the agreed payment plan

contact a financial counsellor or relevant consumer representative if requested. It is important for a customer in Financial Hardship to meet with a person from a relevant consumer representative organisation to discuss their financial situation and consider the options available.

Complaints handling

We will ensure that there are appropriate escalation procedures in place to deal with customer complaints regarding this policy.

If you have a complaint, please contact us first. Our contact details are included below.

If you are not satisfied with the way we handle your complaint, you may refer your complaint to the Energy & Water Ombudsman. The Energy & Water Ombudsman will investigate your complaint and may mediate the dispute between you and us.

Approval and review

Our policy was approved by the Economic Regulation Authority of WA.

This policy will be reviewed biennially to ensure it meets the needs of customers experiencing financial hardship. The review will incorporate the views and recommendations of our stakeholders.
We will ensure procedures and work instructions are reviewed and maintained to ensure hardship customers are dealt with in a sensitive manner according to the guidelines set in this policy.